IR 05000397/2020004
| ML21034A419 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/03/2021 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP |
| To: | Sawatzke B Energy Northwest |
| References | |
| IR 2020004 | |
| Download: ML21034A419 (28) | |
Text
February 3, 2021
SUBJECT:
COLUMBIA GENERATING STATION - INTEGRATED INSPECTION REPORT 05000397/2020004
Dear Mr. Sawatzke:
On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. On January 21, 2021, the NRC inspectors discussed the results of this inspection with Mr. G. Hettel, Chief Nuclear Officer/Vice President Nuclear Generation, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Columbia Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Columbia Generating Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch A Division of Reactor Projects
Docket No. 05000397 License No. NPF-21
Enclosure:
As stated
Inspection Report
Docket Number:
05000397
License Number:
Report Number:
Enterprise Identifier: I-2020-004-0011
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, WA
Inspection Dates:
October 01, 2020 to December 31, 2020
Inspectors:
L. Merker, Senior Resident Inspector
A. Patz, Senior Resident Inspector
W. Sifre, Senior Reactor Inspector
J. Vera, Resident Inspector
R. Alexander, Senior Emergency Preparedness Inspector
J. Drake, Senior Reactor Inspector
N. Hernandez, Operations Engineer
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Columbia Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Identify Gasket Critical Characteristic Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2020004-01 Open/Closed
[H.12] - Avoid Complacency 71111.12 The inspectors identified a Green, non-cited violation (NCV) of 10 CFR Part 50, Appendix B,
Criterion III, associated with the licensees failure to establish measures for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems, and components.
Specifically, the licensee did not establish critical design characteristics for the control room emergency chiller 1B oil separator plate gasket, thus allowing installation of a gasket that did not meet the required width for proper component operation. The improper oil separator plate gasket did not prevent internal oil leakage from the compressor oil sump into the evaporator while in standby.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000397/2020004-02 Reactor Core Isolation Cooling Drainpipe Steam Leak 71111.15 Open
PLANT STATUS
Columbia Generating Station began the inspection period at 100 percent power. On November 11, 2020, reactor power was reduced to 64 percent to perform maintenance on circulating water valve 2C. On November 14, 2020, the reactor was returned to 100 percent power. On November 20, 2020, plant power was reduced to 78 percent due to high-level trips of feedwater heaters 2B and 3B. On November 22, 2020, the reactor was returned to 100 percent power. On December 12, 2020, reactor power was reduced to 62 percent to perform control rod sequence exchanges, control rod scram time testing, turbine valve testing, main steam bypass valve testing, and planned maintenance on the adjustable speed drive 1B1 channel. The unit was returned to rated thermal power on December 13, 2020, where it stayed for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)residual heat removal system B following annual maintenance on October 22, 2020 (2)emergency chilled water system B following chiller 1B maintenance on November 19, 2020 (3)emergency chilled water system A following chiller 1B maintenance on November 19, 2020 (4)residual heat removal system A following annual maintenance on December 11, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Area R-4/2, residual heat removal system B pump room, on October 20, 2020
- (2) Fire Area SW-1/1, standby service water pumphouse 1A, on November 3, 2020
- (3) Fire Area SW-2/2, standby service water pumphouse 1B, on November 3, 2020
- (4) Fire Area ASD, adjustable speed drive building, on November 10, 2020
- (5) Fire Area R-1/1, reactor building 548 foot elevation southeast quadrant, on November 12, 2020
- (6) Fire Area R-5/1, residual heat removal system A pump room, on December 10, 2020
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the residual heat removal systems A and B pump rooms on November 13, 2020.
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the annual requalification operating exam that was administered from November 2, 2020 to December 16, 2020.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a reactor downpower on November 11, 2020, to perform maintenance on circulating water valve 2C, and subsequent return to 100 percent power on November 14, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator training for a station blackout event on October 14, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following SSCs remain capable of performing their intended function:
(1)residual heat removal system B on October 23, 2020 (2)residual heat removal system A on December 10, 2020
Quality Control (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the commercial dedication of the control room emergency chiller 1B oil separator plate gasket remained capable of performing its intended function on December 16, 2020.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1)yellow risk for residual heat removal system B maintenance, week of October 19, 2020 (2)yellow risk for standby gas treatment system A maintenance, week of November 9, 2020 (3)yellow risk for residual heat removal system A maintenance, week of December 7, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)control rod drive valve 10 stroke time exceeded action limit on October 4, 2020 (2)diesel generator 4 output breaker tripped outside of time tolerances during overcurrent trip testing on November 19, 2020 (3)loss of phase B voltage on 6.9kV switchgear bus E-SH-6 on November 30, 2020 (4)standby service water valve 226B failed leakage test on December 2, 2020 (5)residual heat removal valve 3A overthrust condition during diagnostic testing on December 18, 2020 (6)steam leak on reactor core isolation cooling system turbine inlet valve drain line on December 21, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1)circulating water valve 2C actuator removal, motor removal, and gag installation on November 20, 2020 (2)safety-related battery replacements; B2-1 (250 VDC), B1-1 (125 VDC), and B1-2 (125 VDC); on December 23, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
(1)residual heat removal system B on October 29, 2020 (2)scram discharge volume vent and drain valves on November 3, 2020 (3)standby gas treatment system A on November 16, 2020 (4)residual heat removal system A on December 9, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) ESB-B21-Q101, battery B2-1 (250 VDC) quarterly surveillance, on November 4, 2020
- (2) OSP-ELEC-M701, diesel generator 1 monthly surveillance, on November 12, 2020
- (3) OSP-FLEX-Q704, diesel generator 4 quarterly surveillance, on November 30, 2020
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) OSP-INST-H101, shift and daily instrument checks (Modes 1, 2, 3), on December 22, 2020
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system between January 1, 2019, and October 31, 2020.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between January 1, 2019, and October 31, 2020.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between January 1, 2019, and October 31, 2020. This involved review of licensee screening and evaluation documentation. The reviews of the change process documentation do not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program between January 1, 2019, and October 31, 2020.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated simulator-based licensed operator requalification training (Crew F) on August 3,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12)===
- (1) January 1, 2019, through September 30, 2020
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) January 1, 2019, through September 30, 2020
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) January 1, 2019, through September 30, 2020
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) October 1, 2019, through September 30, 2020
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) October 1, 2019, through September 30, 2020
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a significant safety conscious work environment (SCWE) issue. The inspectors reviewed all anonymous action request reports for the period of March 2020, to November 2020 to identify potential SCWE issues.
Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)evaluation of the August 22, 2020, control rod 18-59 misposition event on October 9, 2020 (2)evaluation of the July 10, 2020, inverter 3A failure to transfer to inverter 3B event on December 18, 2020 (3)evaluation of external diverse and flexible mitigation capability (FLEX) equipment operating experience on December 28, 2020
71153 - Follow-up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) The inspectors evaluated the high-level trips of feedwater heater 2B and 3B, resultant reactor downpower to 78 percent, and the licensees response; November 20-21,
INSPECTION RESULTS
Failure to Identify Gasket Critical Characteristic Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000397/2020004-01 Open/Closed
[H.12] - Avoid Complacency 71111.12 The inspectors identified a Green, non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, associated with the licensees failure to establish measures for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSCs. Specifically, the licensee did not establish critical design characteristics for the control room emergency chiller 1B oil separator plate gasket, thus allowing installation of a gasket that did not meet the required width for proper component operation. The improper oil separator plate gasket did not prevent internal oil leakage from the compressor oil sump into the evaporator while in standby.
Description:
On June 19, 2020, control room emergency chiller 1B was shut down during surveillance testing due to low oil pressure. During their investigation, the licensee discovered metal debris in the oil. The licensee declared the chiller inoperable and performed a maintenance overhaul of the chiller from June 27-July 9, 2020. On July 3, 2020, the licensee unknowingly installed an incorrectly sized oil separator plate gasket. The licensee performed a 48-hour operability run and restored the chiller to operable status on July 11, 2020.
On July 13, 2020, an operator discovered the oil level in the compressor oil sump was lowering and entered this issue into the corrective action program under Action Request (AR)408654. The licensee added oil to restore oil level. Over the next few weeks, the licensee experienced repeated low oil levels; however, the licensee maintained the chiller operable by adding oil, doing multiple extended chiller runs, and performing an engineering evaluation.
The licensee performed a second major chiller overall and compressor internal inspection from August 6-17, 2020. On August 12, 2020, the incorrectly sized oil separator plate gasket was reinstalled. Over the next few weeks, the licensee again experienced repeated low oil levels; however, the licensee maintained the chiller operable based on multiple extended chiller runs and support from the previous engineering evaluation.
The licensee performed a third major chiller overall from September 13-October 4, 2020. On September 23, 2020, the licensee identified that an incorrectly sized oil separator plate gasket had been installed. On September 29, 2020, the licensee cut and installed a new gasket with the required width for proper component operation. The licensee restored control room emergency chiller 1B to operable status on October 4, 2020.
Title 10 CFR Part 21, Reporting of Defects and Noncompliance, establishes the framework for an acceptance process under the definition for dedication, to provide reasonable assurance that a commercial grade item to be used as a basic component will perform its intended safety function, and in this respect, is deemed equivalent to an item designed and manufactured under a 10 CFR 50, Appendix B, Quality Assurance program. This assurance is achieved by identifying the critical characteristics of the item and verifying their acceptability. Title 10 CFR 21.3, Definitions, defines critical characteristics, in part, as those important design, material, and performance characteristics of a commercial grade item that, once verified, will provide reasonable assurance that the item will perform its intended safety function. Title 10 CFR 21.3 also requires that the dedication process be conducted in accordance with the applicable provisions of 10 CFR Part 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, includes the provisions for quality assurance and quality control which are applicable to the acceptance and dedication process for commercial-
-grade design and fulfills the Appendix B to 10 CFR Part 50 requirement established by the definition of dedication in 10 CFR Part 21 for commercial-grade dedication programs.
Criterion III requires, in part, that measures be established to assure that applicable regulatory requirements are correctly translated into specifications, drawings, procedures, and instructions; and that measures be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSCs.
The inspectors noted that the gasket was a commercially-dedicated basic component.
During their review, the inspectors could not locate any specified critical characteristics (such as proper dimensions) in the licensees paperwork associated with the gasket other than a limitation on use statement that noted to verify proper size/fit at installation. The inspectors determined the licensee verified the part number supplied from the vendor and assumed the gasket was the correct size.
Corrective Actions: The licensees corrective actions included declaring control room emergency chiller 1B inoperable, performing an engineering analysis and starting the chiller to demonstrate operability, and replacing the incorrectly sized gasket.
Corrective Action References: ARs 408708, 409203, 411103, and 411140
Performance Assessment:
Performance Deficiency: The failure to establish measures for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSCs was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not establish critical design characteristics for the control room emergency chiller 1B oil separator plate gasket, thus allowing installation of a gasket that did not meet the required width for proper component operation. The improper oil separator plate gasket did not prevent internal oil leakage from the compressor oil sump into the evaporator while in standby.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating system, structure or component where operability or probabilistic risk assessment (PRA) functionality was maintained.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. This finding had a cross-cutting aspect in the area of human performance, avoid complacency, in that the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee verified the part number supplied from the vendor and assumed the gasket was the correct size.
Enforcement:
Violation: Title 10 CFR 21.3 requires, in part, that the dedication process be conducted in accordance with the applicable provisions of 10 CFR Part 50 Appendix B. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, design control measures for the selection and the review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSCs.
Contrary to the above, on July 3, 2020, and August 12, 2020, the licensee failed to ensure the dedication process was conducted in accordance with the applicable provisions of 10 CFR Part 50, Appendix B, and establish measures for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-
-related functions of the SSCs. Specifically, the licensee did not establish critical design characteristics for the control room emergency chiller 1B oil separator plate gasket, thus allowing installation of a gasket that did not meet the required width for proper component operation. The oil separator plate gasket did not prevent internal oil leakage from the compressor oil sump into the evaporator while in standby.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Reactor Core Isolation Cooling Drainpipe Steam Leak URI 05000397/2020004-02 71111.15
Description:
An unresolved item was identified associated with a steam leak. On September 18, 2020, the licensee discovered a steam leak on the reactor core isolation cooling (RCIC) system turbine steam inlet valve drain line during recovery from a planned RCIC maintenance window. This issue was entered into the corrective action program under Action Request (AR) 410929. The licensee performed an operability determination that stated the RCIC system was operable with the steam leak because the leak was would not impact the required steam flow to the RCIC turbine. The licensee restored the RCIC system to normal standby lineup which isolated the steam leak on September 18, 2020.
On December 10, 2020, engineering entered AR 414023414023into the corrective action program with a concern that the operability determination from AR 410929410929failed to evaluate the steam leak against American Society of Mechanical Engineers (ASME) code requirements as the drain line was an ASME Section III, Class 2, high-energy pipe. Operations requested additional operability information from engineering to further evaluate operability of the RCIC system. The inspectors identified weaknesses in the additional operability information and determined the licensee needed to perform an ASME code repair on the pipe and submit an ASME code relief request to the NRC. On December 17, 2020, the licensee declared the RCIC system inoperable. On December 19, 2020, the licensee declared the RCIC system unavailable in order to perform the ASME code repair. The licensee restored the RCIC system to operable status on December 20, 2020. The licensee started an event investigation and entered AR 414343414343into the corrective action program to evaluate past operability of the RCIC system. Further review is necessary to determine whether a violation exists.
Planned Closure Actions: The inspectors need to evaluate whether the system turbine steam inlet valve drain line steam leak operability determinations were in violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings" and whether the RCIC system was inoperable for longer than the Technical Specification 3.5.3 allowed outage timeframe of 14 days. The licensee is currently conducting an event investigation and past operability review. The inspectors will need to perform an independent review on past operability and evaluate the licensee's event investigation in order to determine whether a violation exists.
Licensee Actions: The licensee performed an ASME code repair on the turbine steam inlet valve drain line and is conducting an event investigation and past operability review.
Corrective Action References: ARs 410929, 414023, and 414343 Observation: Anonymous Action Requests Trends Identified 71152 The inspectors reviewed all anonymous action requests for the period of March 2020 to November 2020 to identify any potential safety conscious work environment issues. Two minor trends were identified: 1) low-level action items being submitted anonymously for the security group and 2) a continued technical discussion over multiple anonymous action requests. The inspectors noted that these issues would normally be expected to be addressed directly through the action request process, and that the originator being identified is useful in addressing such issues (for example, when reviewers seek clarification or additional details). These two trends could be low-level indicators of unwillingness to freely raise concerns through the corrective action process where the originator is identified. The inspectors discussed these trends with the plant Employee Concerns Program Manager, who indicated that they would consider taking actions to issue a communication to remind employees that they should feel free to raise concerns using the corrective action process.
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public disclosure.
- On November 5, 2020, the inspectors presented the emergency preparedness program inspection results to Mr. R. Schuetz, Site Vice President, and other members of the licensee staff.
- On January 21, 2021, the inspectors presented the integrated inspection results to Mr.
G. Hettel, Chief Nuclear Officer/Vice President Nuclear Generation, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Action Requests
(ARs)
413950, 413997
Drawings
M521-1
Flow Diagram: Residual Heat Removal System Loop "A"
119
M521-2
Flow Diagram Residual Heat Removal Loop "B"
117
M524-1
Flow Diagram Standby Service Water System Reactor,
Radwaste, D.G. Bldg's and Yard
140
M775
Flow Diagram Emergency Chilled Water Piping System
Control Room
29
Procedures
1.3.29
Locked Valve Checklist
087
SOP-HVAC/CR-
LU
Control, Cable, and Critical Switchgear Rooms HVAC Lineup
001
SOP-RHR-LU
RHR System Valve and Breaker Lineup
009
SOP-RHR-STBY
Placing RHR in Standby Status
005
SOP-SW-LU
Standby Service Water System Valve and Breaker Lineup
014
Calibration
Records
FP-02-85-03
Combustible Loading Calculation
010
Fire Plans
Reactor 422
006
Procedures
1.3.10
Plant Fire Protection Program Implementation
036
1.3.10C
Control of Combustibles
2
1.3.57
Barrier Impairment
039
ABN-FIRE
Fire
041
PFP-MN-XFMR-
YD-MISC
MN XFMR YD Misc Bldgs
007
Calculations
ME-02-02-02
Reactor Building Flooding Analysis
004
Corrective Action
Documents
Action Requests
(ARs)
2045
Drawings
M539
Flow Diagram Floor Drain System Reactor Building
090
M723
Embedded Floor & Equipment Drains - Reactor Building
Elevation 422 - 3
005
Miscellaneous
BIP 17-0406
Barrier Impairment Permit to Remove and Reinstall the Floor
Plugs to Support FDR-AO-221 Work
11/03/2020
Procedures
10.2.101
Informational Visual Examinations
005
10.2.208
Borg Warner Gate Valve Model 401HBC6-003 with Magna
Thrust Operator
2
10.2.251
Installation of Temporary Flood Barriers
000
ABN-FLOODING
Flooding
2
OSP-FDR/IST-
Q702
FDR Secondary Containment Valve Operability
006
Work Orders
2145870, 02109343, 02152587
71111.11Q Corrective Action
Documents
Action Requests
(ARs)
2246, 412947, 412961, 412964
Engineering
Changes
18557
CW-V-2C Gag Temp Mod
000
Miscellaneous
Control Rod Withdrawal Deviation Sheet
11/11/2020;
11/13/2020
Reactivity Control Plan to Recover from Circ Water Valve
Repair - November 2020
11/11/2020
Procedures
13.1.1
Classifying the Emergency
047
3.2.6
Power Maneuvering
015
4.603.A8
603.A8 Annunciator Panel Alarms
043
5.6.1
SBO/ELAP Chart
030
5.6.2
Station Blackout SBO and Extended Loss of AC Power ELAP
Attachments
015
9.3.12
Plant Power Maneuvering
037
9.3.9
Control Rod Withdrawal Sequence Development and Control
030
ABN-CORE
Unplanned Core Operating Conditions
018
ABN-ELEC-LOOP Loss of All Offsite Electrical Power
017
ABN-
TRANSFORMER
Transformer Abnormal Operation
26
SOP-CR-
MOVEMENT
Control Rod Movement
004
Corrective Action
Documents
Action Requests
(ARs)
410313, 412073, 412115, 408708, 409203, 411103, 411140,
411639, 413950, 413964, 413949, 413955, 413945, 413873,
2326, 388782, 390620, 332326, 396010, 372892, 396502
Miscellaneous
CGS RHR System Health Report dated November 4, 2020
BIP 20-0195
Barrier Impairment for ISP-RHR-X304
10/20/2020
PL-0002
Standard Procurement and Use Policy for Gaskets
28
Procedures
1.10.11
Technical Assessments Supporting Reportability and
Reportability Evaluations
2
1.3.64
Plant Clearance Order
044
1.5.11
016
10.2.10
Fastener Torque and Tensioning
28
10.25.105
Motor Control Center and Switchgear Maintenance
039
10.25.13A
4.16KV Vacuum Breaker Maintenance and Stored Energy
Mechanism
21
10.25.168
Maintenance and Repair of Limitorque Valve Operators -
Model SMB and SB 0 Through 4
013
3.4.1
Minimizing the Potential of Draining the Reactor Vessel -
21
ECCS-LPCI (B and C) Pump Discharge Low (Minimum Flow) -
008
MWES-2
Engineering Standards for Standard Recommended Practice
004
SPES-1.6.17
Procurement Specifications
055
SPES-1.6.5
050
SPES-1.7.41
Critical Characteristic/Equipment Concerns
046
SPES-1.9
9.0 Appendixes [sic]
055
SQI-10-3
Receiving Inspection
2
SQI-18-4
Commercial Grade Item Survey
009
SQI-7-2
Evaluation of Suppliers
2
SWP-PUR-02
Procurement Technical Reviews
010
SWP-PUR-04
Material, Equipment, Parts, and Supplies Procurement
016
SYS-4-31
System and Equipment Performance Monitoring and Trending
Program
2
WCI-2
Standard Operating Cycle Schedule Development
006
Work Orders
2168795, 02115864, 02135659, 02139791, 02161200,
2153094, 02152781, 02160160, 02160196, 02168795,
2039377, 02124750, 02107556, 02169507, 02149765,
2159074, 02146580, 02110027, 02111170, 02149765
Corrective Action
Documents
Action Requests
(ARs)
2851, 412858, 412859, 412901
Corrective Action
Documents
Resulting from
Inspection
2066
E-TR-IN/2 buzzing
10/19/2020
2116
Transient combustible permit expired
10/20/2020
2117
Transient combustible permit inaccurate
10/20/2020
Miscellaneous
Operator Logs: December 7 - 8, 2020
2/08/2020
BIP 20-0325
Barrier Impairment Permit for PPM 15.1.17 Ventilation Air
Flow Test
11/10/2020
BIP 20-0555
Barrier Impairment Permit for Propping Door R614 Open
2/08/2020
FSIP 20-0207
Fire System Impairment Permit for Standby Gas Treatment
System A Filter Unit 1A
11/10/2020
Procedures
1.3.10
Plant Fire Protection Program Implementation
036
1.3.10C
Control of Combustibles
2
1.3.57
Barrier Impairment
039
1.3.76
Integrated Risk Management
060
1.3.83
Protected Equipment Program
2
1.5.14
Risk Assessment and Management for
Maintenance/Surveillance Activities
043
Work Orders
2161050, 02104163, 02131361, 02111170
Calculations
E/I-02-95-01
Overcurrent Protective Device Settings & Coordination
Calculation for 480 Volt Distribution Systems
007
ME-02-01-30
Determination of RCIC Availability without Standby Service
Water
000
ME-02-92-43
Room Temperature Calculation for DG Building, Reactor
Building, Radwaste Building and Service Water
013
RCIC-1482-1
Drain from RCIC-DT-1 to Drip Leg
2
RCIC-1482-2
Drain from RCIC-DT-1 to Drip Leg
2
Corrective Action
Documents
Action Requests
(ARs)
2595, 372062, 372279, 397571, 411575, 409695, 409856,
409857, 410954, 411040, 391735, 393301, 393370, 403897,
413171, 413175, 413474, 412247, 413950, 410929, 414023
Drawings
317-00,2130
Drain from RCIC-DT-1 to Drip Leg
010
EWD-3E-017
Electrical Wiring Diagram Reactor Recirculation System 6.9kV
SWGR E-SH-6 BRDR RRC-CB-RRB
014
EWD-46E-042
Electrical Wiring Diagram AC Electrical Distribution Systems
6.9kV Bus 6 and E-TR-S X Winding UNDV
009
M519
Flow Diagram: Reactor Core Isolation Cooling
103
M775
Flow Diagram Emergency Chilled Water Piping System
Control Room
29
Engineering
Changes
17708
Diesel Generator 4 (DG4) Output Breaker Replacement
001
18566
TMOD Remove SH-6 UV Relay E-RLY-27/6
000
Miscellaneous
ASME Piping Systems
24
RHR-MO-3A
MOV Master Data Sheet
009
RHR-MO-3A
Overthrust Evaluation
2/08/2020
TM-2150
Mission Time of Emergency Safety Features
001
Procedures
1.3.66
036
1.5.1
Surveillance Testing Program
043
MES-3
Piping Design Guide
005
OSP-CCH/IST-
M702
Control Room Emergency Chiller System B Operability
045
OSP-CRD/IST-
Q701
Scram Discharge Volume Vent and Drain Valves Operability
008
OSP-RHR/IST-
Q702
RHR Loop A Operability Test
053
Work Orders
2119234, 02163216, 02170796, 02170824, 02155871,
2145984, 29157385, 29157394, 02077609, 02151526,
2172876, 29157097, 02126182, 02171498, 02159074,
2169507, 02172942
Corrective Action
Documents
Action Requests
(ARs)
407479, 412859, 412915, 412988, 393512, 393661, 402407,
403247, 407256, 407800, 408773, 409608, 412116, 412117
Engineering
Changes
204
TMOD for Online Station Battery E-B2-1 Replacement
000
18317
TMOD for Online Station Battery E-B1-1 and E-B1-2
Replacement
000
18557
CW-V-2C Gag Temp Mod
000
Miscellaneous40-000,47
Butterfly Valves & Operators Owner's Manual
2
ISP 20-0204
Ignition Source Permit for CW-V-2C Welding
11/13/2020
TCP 20-0198
Transient Combustible Permit for CW-V-2C
11/13/2020
Procedures
1.3.57
Barrier Impairment
039
1.3.9
057
10.2.226
Mechanically Gagging Equipment
2
10.25.219
Online Battery Replacement of 125 VDC E-B1-1
000
10.25.230
Online Battery Replacement of 125 VDC E-B1-2
000
10.25.236
Online Battery Replacement of 250 VDC E-B2-1
000
SWP-DES-01
Plant Modifications & Configuration Control
017
Work Orders
2172415, 02091531, 02115649, 02124385, 02157379
Corrective Action
Documents
Action Requests
(ARs)
2115, 412073, 412159, 373358, 411575, 412368, 412378,
2823, 412890, 412901, 412661
Miscellaneous
Operations Department Narrative Logs for December 9, 2020
BIP 20-0325
Barrier Impairment Permit for PPM 15.1.17 Ventilation Air
Flow Test
11/10/2020
BIP 20-0418
Barrier Impairment Permit to Open Doors of SGT-FU-1A
11/11/2020
FSIP 20-0207
Fire System Impairment Permit to Isolate & Test Deluge
Nozzles per PPM 15.1.17
11/10/2020
Procedures
15.1.17
Ventilation Deluge Systems Air Flow Test
017
OSP-CRD/IST-
Q701
Scram Discharge Volume Vent and Drain Valves Operability
008
RHR B Fill Verification
2
OSP-RHR/IST-
Q702
RHR Loop A Operability Test
053
OSP-RHR/IST-
Q703
RHR Loop B Operability Test
060
Standby Gas Treatment System A Operability
018
Procedures
OSP-SGT/IST-
Q701
SGT Valve Operability (System A)
010
SWP-TST-01
Post Maintenance Testing Program
017
Work Orders
2115864, 02156981, 02134952, 02168795, 02163216,
2170824, 02170796, 02104163, 02112327, 02131362,
2161050, 02161072, 02169507, 02149765, 02159074
Corrective Action
Documents
Action Requests
(ARs)
2774, 369958, 312509, 410018, 411138, 411854, 414249
Miscellaneous
Instrument Master Data Sheet for FDR-FQ-38
003
Exide Instruction Manual
008
Procedures
8.4.54
Thermal Performance Monitoring of DCW-HX-1A1 and DCW-
HX-1A2
010
Quarterly Battery Testing 250VDC E-B2-1
013
ISP-FDR/EDR-
M401
Drywell Sump Flow Monitors - CFT
007
ISP-FDR/EDR-
X301
Drywell Sump Flow Monitors - CC
011
DO-P-1A Operability
001
Offsite Station Power Alignment Check
2
OSP-FDR/IST-
Q701
FDR Valve Operability
004
Diesel Generator 4 Quarterly Surveillance
000
Shift and Daily Instrument Checks (Modes 1, 2, 3)
094
SOP-FDR-OPS
Floor Drain System Operation
003
TSP-DG1-X501
DG1 Shutdown Logic Checks
003
Work Orders
2134491, 02134497, 02136100, 02160766, 02168151,
29156291, 02163167, 02135995
Corrective Action
Documents
Action Requests
(AR)
391263, 391789, 392263, 392551, 400727, 403397, 406956,
407353
Corrective Action
Documents
Resulting from
Inspection
Action Requests
(AR)
2662
Miscellaneous
Alert and Notification System (ANS) Design Report - Revision
11/14/2016
CGS ANS Annual Report for 2019 (to FEMA Region X)
01/29/2020
Procedures
TSI-6.2.22
EP Annual Emergency Response Siren System Activation
Test
004
TSI-6.2.32
003
TSI-6.2.48
2
TSI-6.2.49
EP River Siren Post-Maintenance Test
001
TSI-6.3.8
EP ANS System Battery Replacements
000
Work Orders
EP Inspect Siren Sites (per TSI-6.2.48)
05/20/2020
ESSN Perform Siren System Polling Test (per TSI-6.2.32)
11/04/2020
Corrective Action
Documents
Action Requests
(AR)
2339, 396868, 400339, 401462, 4040980, 407465, 408060
Corrective Action
Documents
Resulting from
Inspection
Action Requests
(AR)
2612, 412757
Miscellaneous
Quarterly Off-Hours ERO Notification Drill Results (per EPI-19) 1Q/2019,
2Q/2019,
3Q/2019,
1Q/2020,
2Q/2020,
3Q/2020
Annual Unannounced ERO Call Out Drill (per EPI-19,
conducted 11/6/2019)
11/14/2019
CGS ERO On-Shift Staffing Analysis Report (Rev 3)
07/08/2018
Procedures
13.10.1
Control Room Operation and Shift Manager Duties
035
13.4.1
Emergency Notifications
044
EPC 26045
Energy Northwest Emergency Classification or Other
Emergency Messages
036
EPI-19
Communications Tests
010
OI-34
Notifications
039
SWP-EPP-01
Emergency Response Organization and Training
2
Corrective Action
Documents
Action Requests
(AR)
389508, 390488
Miscellaneous
2019 50.54(q) Tracking Log
20 50.54(q) Tracking Log
Tracking No.
2019-03
50.54(q) Screen - All EPIPs in Attachment 4 of CGS
Emergency Plan (Update to References)
03/18/2019
Tracking No.
2019-13
50.54(q) Screen for PPM 13.14.9, Emergency Program
Maintenance, Revision 30
05/07/2019
Tracking No.
2019-18
50.54(q) Screen for PPM 13.10.8, Security Lieutenant and
Security Force Duties, Revision 26; and EPC 26573, SCC
Duty Officer Checklist, Revision 8
10/01/2019
Tracking No.
2019-18
§ 50.54(Q) Change Evaluation for PPM 13.10.8, Security
Lieutenant and Security Force Duties, Revision 26
10/02/2019
Tracking No.
20-15
50.54(q) Screening for PPM 13.8.1, Emergency Dose
Projection System Operations, Revision 39, Minor Revision 05
03/17/2020
Procedures
EPI-16
§ 50.54(Q) Change Evaluation
016
Corrective Action
Documents
Action Requests
(AR)
388485, 388568, 390016, 390017, 392049, 394205, 395491,
397304, 397614, 397852, 398002, 398872, 399147, 399484,
401722, 402961, 403544, 403778, 403836, 404033, 404038,
404211, 404328, 405708, 405883, 407302, 407305, 407311,
407313, 407353, 407561, 407596, 409240, 412623,
Miscellaneous
Memorandum of Understanding Between Energy Northwest
and
- U.S. Department of Energy, Richland Operations Office,
for Emergency Preparedness and Response
10/09/2020
Memorandum of Understanding Between Framatome Inc. and
Energy Northwest October 2018
11/09/2018
Letter of Agreement Between Energy Northwest and Kadlec
Regional Medical Center
10/30/2012
ERO Team B Drill Report - August 25, 2020
09/29/2020
ERO Team D Dress Rehearsal Drill Report - February 25,
20
03/19/2020
8-Year Exercise Cycle Element Tracking
10/20/2020
Miscellaneous
Plant Health Committee Presentation - Emergency
Preparedness System Health Report Summary
09/15/2020
ERO Team A Drill Report - September 10, 2019
10/10/2019
ERO Team B Drill Report - July 16, 2019
08/06/2019
ERO Team C Drill Report - February 19, 2019
2/19/2019
ERO Team D Drill Report - October 29, 2019
11/26/2019
2019 Field Sampling Team Drill Report
10/15/2019
AR 388340388340EP Department MOU Review Tracker - 2019
AR 388343388343On-Site Medical Emergency Drill 2019 - Contaminated/Injured
Man
09/03/2019
AR 388355-03
2019 Fire Drill with Hanford Fire Department
2/12/2019
AR 3986873986872019 Chemistry Liquid Sampling Drill Report
2/03/2019
AR 40083640083620 Emergency Preparedness Program 12-Month Audit
Frequency Evaluation (50.54(t) Review)
2/06/2020
AR 40282940282920 Field Team Monitoring Sampling Team Drill
01/22/2020
AU-EP-19
Quality Services Audit Report: Emergency Preparedness
Program (50.54(t) Review)
03/14/2019
Emergency Plan - Columbia Generating Station
066, 067
Development of Evacuation Time Estimates, Rev. 0
10/2012
KLD TR-1106
Columbia Generating Station: 2019 Population Update
Analysis
09/25/2019
KLD TR-1186
Columbia Generating Station: 2020 Population Update
Analysis
09/23/2020
Procedures
13.1.1A
Classifying The Emergency - Technical Bases
034
13.10.2
TSC Manager Duties
035
13.10.9
Operations Support Center Manager and Staff Duties
050
13.11.1
EOF Manager Duties
044
13.14.11
EP Equipment
014
13.14.8
Drill and Exercise Program
018
13.14.9
Emergency Program Maintenance
030
13.2.2
Determining Protective Action Recommendations
20
EPI-17
After Action Report / Improvement Plan Formatting,
Distribution, and Retention
008
EPI-21
Drill and Exercise Development and Implementation
019
Procedures
SWP-CAP-01
Corrective Action Program
2
SWP-CAP-06
Condition Report Review
27
Self-Assessments SA 371289
Focused Self-Assessment Report: Emergency Preparedness
Exercise Year Self-Assessment
2/03/2019
SA 386590
Snap-Shot Self-Assessment Report: Columbia Generating
Station Emergency Preparedness Non-Exercise Year
10/01/2020
Work Orders
ICP-MET-S302: Meteorological Rain Gauge & Temperature
Monitoring Instrumentation Channel Calibration
10/01/2019
AMA-AH-51 Will Not Maintain Temperatures in TSC
08/28/2019
Replace and Test ARM-RE-34
08/12/2020
Replace MET-TE 10A, 10B, 11A and 11B: ICP-MET-S302
07/08/2020
Received 602.A5.1-1 Refuel Floor Area Rad High Alarm
10/16/2020
Corrective Action
Documents
Action Requests
(ARs)
409496
Miscellaneous
AOM-T Roll-up Comments: Cycle 20-04
000
Crew F 4.0 Critique Summary LR002492
08/03/2020
Drill, Exercise, and Actual Events Opportunity Crew F
Evaluation: Event 2020-15
08/03/2020
Form 24075
Columbia Generating Station Classification Notification Form
(CNF)
24
Form 25665
Reactor Plant Event Notification Worksheet Form
004
Form 26045
Energy Northwest Emergency Classification or Other
Emergency Messages Form
036
Form 26051
Energy Northwest Public Address Emergency Message for
Site Evacuation Form
013
LR002492
Cycle 20-4 Evaluated Scenario
000
Procedures
13.1.1
Classifying the Emergency
049
13.1.1A
Classifying the Emergency - Technical Bases
034
13.2.2
Determining Protective Action Recommendations
20
13.4.1
Emergency Notifications
044
13.5.1
Local, Protected Area or Site Evacuation
031
Emergency Plan Columbia Generating Station
067
EPI-18
Emergency Preparedness Performance Indicators
27
71151
Corrective Action
Documents
Action Requests
(AR)
391263, 391789, 396911, 402143
Action Requests
(ARs)
400472
Corrective Action
Documents
Resulting from
Inspection
Action Requests
(AR)
2568
Miscellaneous
Monthly Key ERO Member Qualification Records
1Q/2019 -
3Q/2020
Select DEP PI Opportunity Assessments: 2019-04, 2019-05,
2019-09, 2019-14, 2019-16, 2019-18, 2019-20, 2019-27,
2019-32, 2020-08, 2020-11, 2020-12, 2020-13, 2020-14,
20-15, 2020-16
Operations Logs
10/01/2019 -
09/30/2020
Procedures
CI-10.17
2
CSP-I131-W101
Reactor Coolant Isotopic Analysis for I-131 Dose Equivalent
009
EPI-18
Emergency Preparedness Performance Indicators
27
Shift and Daily Instrument Checks Modes 1, 2, 3
094
Work Orders
2120129, 02135838
Corrective Action
Documents
Action Requests
(ARs)
410059, 410060, 410066, 410067, 410096, 411554, 411765,
405158, 405159, 405652, 406513, 407846, 408060, 408789,
409527, 409528, 409529, 409530, 409585, 409586, 409587,
409729, 409730, 409731, 409732, 409733, 409734, 410509,
410834, 410850, 410967, 412918, 413001, 413080, 413262,
408616, 408620, 408622, 408656, 408724, 408741, 410656,
410659, 410677, 410717, 410720, 413485, 368369, 390048,
404936, 406864
Drawings
E504-1
Vital One Line Diagram
006
Engineering
Changes
17708
Diesel Generator 4 (DG4) Output Breaker Replacement
001
Miscellaneous
Technical Issue Resolution Cause Evaluation Sheet for E-
ATS-IN/3
09/29/2020
Miscellaneous
Technical Issue Resolution Fact Sheet for E-ATS-IN/3
09/29/2020
Operator Logs: August 21 - 23, 2020
10/08/2020
Columbia Nuclear Generating Plant - Nuclear Safety Culture
Assessment March 9 - 13, 2020
04/20/2020
Procedures
1.3.84
Reactivity Management Control
006
10.25.1
Inspections and Cleaning Division 1, E-IN-3A and E-IN-3B,
and Division 2, E-IN-2A and E-IN-2B, Inverters
27
4.800.C1
800.C1 Annunciator Panel Alarms
031
ABN-ELEC-INV
20 VAC Critical Distribution System Failures
017
ABN-ROD
Control Rod Faults
031
FLEX-01
FLEX Program
003
OI-09
Operations Standards and Expectation
078, 079
OPEX-01
Operating Experience Program Implementation Manual
010, 011
Control Rod Exercise
27, 028
SOP-CR-
MOVEMENT
Control Rod Movement
003, 004
SOP-ELEC-IN3-
IN3 Operations
013, 014
SWP-CAP-01
Correction Action Program
041, 042
SWP-OPX-01
Operating Experience Program
001
Work Orders
2157506, 29155689, 29155696, 29156799, 29156806,
2131744, 02151530, 02166850, 02148039
Drawings
M503
Flow Diagram Extraction Steam & Heater Vents Turbine
Generator Building
016
M505-1
Flow Diagram Heater Drain System Turbine Generator
Building
21
M505-2
Flow Diagram Heater Drain System Turbine Generator
Building
015
Procedures
ABN-FWH-
HILEVEL/TRIP
Feedwater Heater High-Level Trip
007
SOP-MSR-OPS
Main Turbine Moisture Separator Reheater Operations
010
Work Orders
2172871